APPENDIX IX

Office of the Inspector General's
Analysis of Managements' Responses

On August 21, 1998, the Inspections Division sent copies of the draft report to the Director, Executive Office for United States Attorneys (EOUSA), the United States Attorney for the District of Columbia (USAO), and the Director, Federal Bureau of Investigation (FBI). We addressed five recommendations to the EOUSA concerning Operation Ceasefire and Safe Streets. We received separate responses from the EOUSA, the USAO, and the FBI. Our analysis of these responses to the draft report follows.

Recommendation Number:

1. Resolved-Open. The United States Attorney for the District of Columbia responded that the USAO would submit past due quarterly financial and progress reports to the EOUSA. In addition, the United States Attorney indicated in her response that a correction had been made to the Financial Management Information System (FMIS) to reflect the purchase of computers, and indicated a payment correction form would be completed to move payment from the Office's cost center code to Operation Ceasefire's cost center code. The United States Attorney also responded that the FMIS had been updated to reflect the purchase of fingerprint kits and that a reimbursable agreement had been prepared with the District of Columbia government for this purchase. We agree with the proposed corrective actions and with those already taken. Please provide us a copy of the past due quarterly reports, the payment correction form, documentation that the FMIS has been updated to reflect the purchase of computers and fingerprint kits, the reimbursable agreement, and documentation that the District of Columbia government has been reimbursed for the fingerprint kits.
   
   
2. Resolved-Open. The EOUSA and the United States Attorney for the District of Columbia responded that any improper reimbursements made to the Metropolitan Police Department (MPD) should be recovered. However, the United States Attorney's response stated that the MPD did not agree that any amounts were paid in error, and stated that the USAO was not in a position to refute the MPD's claim. Therefore, the United States Attorney requested that we perform a complete audit on all overtime invoices, as our inspection finding was based on a sample of invoices. We agree with the USAO that a complete audit of Operation Ceasefire overtime expenditures should be performed to determine the total dollar amount of improper reimbursements. However, at this time, our office does not have resources available to conduct such an audit. Please provide us the results of the audit when completed.
   
   
3. Resolved-Open. The EOUSA and the United States Attorney for the District of Columbia responded that the USAO plans to use a Local Law Enforcement Block Grant (LLEBG) Program Award to fund police officer overtime for Operation Ceasefire and would prefer to use the remaining VCTF funds for equipment needs. We agree that the remaining funds be used for office and computer equipment as the USAO prefers. Please provide documentation detailing the office and computer equipment to be purchased.

The EOUSA and the United States Attorney also responded that the USAO would implement a new reimbursable agreement for LLEBG overtime with the MPD that includes our recommended provisions. However, the United States Attorney responded that the USAO would defer this action until a complete audit of overtime invoices has been conducted and after consultation with the Department of Justice Bureau of Justice Assistance and the District of Columbia Office of Grants Management and Development. We agree with the inclusion of our recommended provisions in a new reimbursable agreement with the MPD for LLEBG overtime. Because remaining VCTF funds will not be used for overtime, we do not require any further action in response to this portion of the recommendation.

4. Resolved-Open. The United States Attorney for the District of Columbia responded that the USAO agreed with our recommended actions, and will designate and train an employee assigned to serve as the Operation Ceasefire property custodian on the property management responsibilities. The EOUSA responded that it will ensure that the USAO implements these actions. We agree with the proposed corrective actions. Please provide us documentation that a VCTF property custodian has been designated, confirmation that property records have been established, and documentation showing that the vehicles have been retitled to the United States Attorney's Office.
   
   
5. Resolved-Open. The EOUSA did not comment on our recommendation for Safe Streets, but responded that the FBI indicated that it would draft a memorandum to officials in the FBI's Washington Field Office (WFO) advising them of policy changes regarding the internal controls and review of overtime invoices. The FBI responded that it disagreed with certain findings that formed the basis of our recommendation and cited existing FBI policy that addressed our findings. In addition, the FBI responded that the WFO never had a policy to prohibit the reimbursement of overtime for officers above the rank of sergeant, which contradicts information provided to us by the WFO Safe Streets Coordinator during our review. The FBI should ensure that WFO staff are aware that existing FBI policy does not prohibit overtime reimbursement according to rank.

The FBI also responded that it recognized a need to further strengthen the administrative and internal controls over the review of overtime invoices. Specifically, the FBI responded that it will reinstitute the practice of requiring all officers to utilize the FBI's FD-420 attendance form, which will be compared on a monthly basis to each officer's PD-1130 time and attendance form to ensure accurate reporting of time on duty for overtime purposes. We agree with the proposed corrective actions. Please provide us a copy of the revised FBI policy memorandum regarding the internal controls and review of overtime invoices. During our review, we were not informed of any existing FBI policy on overtime matters, therefore please provide a copy of all existing "All Offices" communications mentioned in the FBI's response regarding overtime reimbursement. In addition, please provide documentation that demonstrates the FBI has informed its staff that the practice of requiring the FD-420 has been reinstituted.